Privacy Policy

Topishi respects your privacy and is committed to protecting your Personal Data. This Privacy Policy will inform you as to how we look after your Personal Data when you visit our Platform and use our Services (regardless of where you visit it from) and will tell you about your privacy rights. Please use the Definitions below to understand the meaning of some of the terms used in this Privacy Policy. Unless specifically defined, terms used throughout this Privacy Policy have the same definitions as those given in Topishi’s General Terms and Conditions. Please read this Privacy Policy carefully before using the Platform or submitting any information to us. By visiting our Platform and using our Services, you shall be deemed to have read, understood and agreed to be bound by this Privacy Policy. If you access the Platform or use the Services on behalf of your child, you represent that you are acting as their legal guardian and have the authority to accept this Privacy Policy on their behalf and consent on their behalf to our collection, use and processing of their Personal Data as provided in this Privacy Policy. If you do not agree to any part of this Privacy Policy, you shall immediately cease from accessing Topishi’s Platform or using any of our Services.

1. Definitions


a. “Applicable Law” means all the laws, rules, regulations, notifications, guidelines, ministerial decisions or cabinet resolutions in force and effect, as of the date hereof and which may be promulgated or brought into force and effect hereinafter in the United Arab Emirates, including judgments, decrees, injunctions, or orders of any court of record, as may be in force and effect during the subsistence of this Privacy Policy.
b. “Comply with a Legal or Regulatory Obligation” means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to in accordance with the Applicable Law.
c. “Data” means personal and non-personal User’s data that is submitted, generated, featured and displayed through the Platform, collected from the use of the Services and stored on Topishi’s servers.
d. “Legitimate Interest(s)” means the interest of our business in conducting and managing our Services to enable us to give you the best Services and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our Legitimate Interest. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by Applicable Law). You can obtain further information about how we assess our Legitimate Interests against any potential impact on you in respect of specific activities by contacting us.
e. “Performance of our Services” means processing your Data where it is necessary for the performance of our Services.
f. “Privacy Policy” means all of the privacy policies, practices and notices contained or referenced in this document (as amended from time to time) and all other Topishi rules, policies available on the Platform that may be published from time to time on the Platform.
g. “Topishi” “we” and “us” collectively mean TOPISHI LLC, as well as our affiliates and subsidiaries.
h. “Topishi’s Terms and Conditions” means all of the terms, conditions and notices contained or referenced in Topishi’s General Terms and Conditions and all other Topishi rules, policies (as amended from time to time) available on the Platform.
i. “User”, “you” or “your” collectively mean the person, that uses and/or visits our Platform and/or the Service. A User may be a Client, a Medical Expert, both, or neither.

2. Important information and who we are


2.1 Purpose of this Privacy Policy: This Privacy Policy aims to give you information on how Topishi collects and processes your Personal Data through your use of this Platform, including any Data you may provide through the Platform when you register an Account, use any Services and/or sign up to our newsletter, as well as installing and signing up to any Topishi App. It is important that you read this Privacy Policy together along with Topishi’s Terms and Conditions, which may be amended from time to time, or any fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them. Please note that it is substantial that the Personal Data we hold about you is accurate and current. Please keep us informed and updated if your Personal Data changes during your relationship with us.

2.2 Changes to the Privacy Policy and your duty to inform us of changes You agree that Topishi may amend this Privacy Policy from time to time, and in Topishi’s sole discretion. You agree and undertake to review our Privacy Policy each time you visit our Platform and/or prior to your use of any Services. Although we will use our best endeavors to notify you of any amendment to this Privacy Policy through a dedicated link available at our Platform, we will not be required to provide you with prior notification of such amendments or changes to this Privacy Policy and your continued use of the Platform or Services shall constitute your acceptance of such amendments or changes to the Privacy Policy.

2.3 Third-party links The Platform may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. We are not responsible for the security of such other sites, nor their terms of use or privacy policies.

3. The data we collect about you


3.1 What Is Personal Information?

3.1.1 “Personal information” or “Personal Data” collectively mean information that specifically identifies an individual (such as a name, address, telephone number, mobile number, e-mail address, office location, professional and personal interests, company name, title department, spoken languages) or information about that individual that is directly linked to personally identifiable information.

3.1.2 Depending on which of our Services you use and how you interact with our Platform, we collect different kinds of information from or about you. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

a. Identity Data includes first name, last name, address, username or similar identifier, title, date of birth and gender.
b. Health Data includes the information related to the state of physical, physiological and mental health of the Client and includes records regarding the past, present or future state of the health of such Client, information collected in the course of registration for, or provision of health services, and information associating the Client to the provision of specific health services.
c. Health Data Documents includes documents related to Health Data including but not limited to medical records, laboratory test results, medical referral letters and prescriptions.
d. Contact Data includes billing address, delivery address, location, email address and/or telephone numbers.
e. Payment Data includes bank account and payment card details, payment history.
f. Transaction Data includes details about payments to and from you and other details of the Services you have purchased through our Platform.
g. Technical Data includes internet protocol (IP) address, your login data, browser type and version, make and model (mobile phones only), operating system, hardware version, platform, device settings and other technology identification on the devices used to access our Platform, file and software names and types, device identifiers, time zone setting and location, device locations such as through GPS, Bluetooth or WiFi signals, browser plug-in types and versions, operating system and platform, connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
h. Profile Data includes any Medical Expert Profile information, any User’s username and password, any purchases made by a User, your interests, preferences, feedback and survey responses.
i. Usage Data includes information about how you use our Platform, Services and other products and how you use your devices to access our Platform, including the screens you visit and searches you make.
j. Special Categories of Personal Data includes details about your race or ethnicity or religion.
k. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
l. Other Data includes:

i. Photos, files or other data uploaded onto any of our Platform by you or shared with other Users of our Platform by you via our Platform;
ii. communications with us via social media platforms, email, electronic messages and other electronic and non-electronic communications;
iii. third-party partner information related to how you use our Platform, such as your reviews of the Medical Experts.
iv. your networks and connections made available to us, depending on the permissions you have granted, from your mobile and desktop devices' address book contacts, and other social media such as Facebook, Instagram, Pinterest and Twitter.

3.1.3 We also collect, use and share aggregated Data such as statistical or demographic Data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data as this Data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined Data as Personal Data which will be used in accordance with this Privacy Policy.

3.1.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation or political opinions). Nor do we collect any information about criminal convictions and offenses.

3.2 What Personal Information Do We Collect?

3.2.1 Personal Information you provide us with: We receive and store any information you enter on our Platform or that you provide us with in any other way. The types of Personal Information collected may include your name, address, telephone number, mobile number, e-mail address, company name, user information regarding your use of our Services and Platform, and browser information. The Personal Information you provide is used for such purposes as allowing you to set up an Account and/or complete a Medical Practitioner Profile that can be used to interact with other Users through the Platform, improving the content of the Services, customizing the advertising and content you see, and communicating with you about events and new features. We may also draw upon this Personal Information in order to adapt the Services of our community to your needs, to research the effectiveness of our network and Services, and to develop new tools for the community.

3.2.2 Information collected automatically: When you access the Platform or use the Services, Topishi automatically receives and records information on our server logs from your browser or mobile platform, including your location, IP address, cookie information, and the page you requested. We treat this Data as non-Personal Information, except where we are required to do otherwise under Applicable Law. Topishi only uses this Data in aggregate form. We may provide aggregate information to our partners about how our customers, collectively, use our Platform, so that our partners may also understand how often people use their services and our Services.

3.2.3 If you fail to provide Personal Data: Where we need to collect Personal Data by Applicable Law, or under the terms of a contract we have with you and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel the Services which you have with us, provided that we will notify you if this is the case at the time.

4. How is your Personal Data collected?

We use different methods to collect Data from and about you including through:

a. When you register an Account with our Platform;
b. When you submit your Health Data and Health Data Documents for the purpose of availing the Services;
c. When you communicate with us in writing, by telephone, fax, email or through the Platform or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
d. When you complete (or we complete on your behalf) a Medical Expert application or other forms;
e. From publicly available sources or from third parties, most commonly where we need to conduct background checks about you;
f. Direct interactions: You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes Personal Data you provide when you:

i. apply for our Services;
ii. create an Account on our Platform;
iii. enter a competition, promotion or survey;
iv. enter data for installing or using any Topishi powered application and/or installing or using our App;
v. correspond with us (online or offline including via email addresses and phone numbers), if you contact us;
vi. post Content on our Platform; or
vii. give us some feedback.

g. Automated technologies or interactions. As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
h. Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out above Technical Data from the following parties:

i. analytics providers such as Google;
ii. advertising networks/agencies; and
iii. search information providers.

i. Contact, Financial and Transaction Data from technical and payment providers; and
j. Identity and Contact Data from publicly available sources.

5. How do we share your information?


5.1 Information shared with everyone in the community: If you are a Medical Expert, we may publicly share your Medical Expert Profile such as your name, photo and contact details, office location, details of Services, and any other information that you allow us to share. You can choose what Personal Information you provide as part of your Medical Expert Profile. We recommend that you guard your sensitive information.

5.2 Information shared with Medical Experts: As a Client, if you request for a Service, we may share your Personal Data with the applicable Medical Expert in order to fulfill your request, as applicable. Where any Health Data and Health Data Documents are to be sent via our Platform, only the consulting Medical Expert and Topishi’s medical administration personnel shall be given access to such Health Data and Health Data Documents.

5.3 Business Transfer: In the event that Topishi is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. The promises in this Privacy Policy will apply to your information as transferred to the new entity.

5.4 Protection of Topishi and others: We may release Personal Information when we believe in good faith that release is necessary to comply with the Applicable Law, including laws outside your country of residence; enforce or apply Topishi Terms and Conditions and other agreements; or protect the rights, property, or safety of Topishi, our employees, our users, or others. This includes exchanging information with other companies and organizations (private or government) (including outside of your country of residence) for fraud protection.

6. How we use your Personal Data


6.1 We will only use your Personal Data in accordance with the Applicable Law, or as otherwise provided in this Privacy Policy. Most commonly, we will use your Personal Data in the following circumstances:
a. Where we need to perform the Services;
b. Where it is necessary for our Legitimate Interests (or those of a third party) and your interests, and fundamental rights do not override those interests; or
c. Where we need to Comply with a Legal or Regulatory Obligation.

6.2 Generally, you agree that we do not require your explicit consent for processing your Personal Data, except in the event of sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

6.3 Purposes for which we will use your Personal Data

6.3.1 Performance of our Services
a. We process your Personal Data because it is necessary for the Performance of our Services. In this respect, we use your Personal Data for the following:
i. To assist with preparation of a Service Confirmation for you regarding the Services offered;
ii. To enable the Medical Experts to offer the Services;
iii. To deal with any complaints or feedback you may have; and
iv. For any other purpose for which you provide us with your Personal Data.

b. In this respect, we may share your Personal Data (except your Health Data and Health Data Documents) with or transfer it to the following:
i. Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
ii. Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you;
iii. Our data storage providers; and
iv. Your agents, advisers, intermediaries, and custodians of your assets who you tell us about.

6.3.2 Legitimate interests
a. We also process your Personal Data (except your Health Data and Health Data Documents) because it is necessary for our Legitimate Interests, or sometimes where it is necessary for the legitimate interests of another person, such as Medical Experts. In this respect, we use your Personal Data for:
i. For the administration and management of our business, including recovering the money you may owe to us, and archiving or statistical analysis; or
ii. Seeking advice on our rights and obligations, such as where we require legal advice. In this respect, we will share your Personal Data (except your Health Data and Health Data Documents) with our advisers or agents where it is necessary for us to obtain their advice or assistance and with third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.

6.3.3 Legal obligations
a. We also process your Personal Data for compliances under Applicable Law that we are under. In this respect, we will use your Personal Data for the following:
i. To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws;
ii. As required by tax authorities or any competent court or legal authority. In this respect, we will share your Personal Data (except your Health Data and Health Data Documents) with the following:
1. Our advisers where it is necessary for us to obtain their advice or assistance;
2. Our auditors where it is necessary as part of their auditing functions;
3. With third parties who assist us in conducting background checks; and
4. With relevant regulators or law enforcement agencies where we are required to do so.

6.3.4 Marketing
a. We may send you marketing about the Services we provide which may be of interest to you, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you or in order to update you with information (such as legal or commercial news) which we believe may be relevant to you. We may communicate this to you in a number of ways including by post, telephone, email or other digital channels.

6.3.5 Promotional offers from us
a. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services, and offers may be relevant for you. You may receive marketing communications from us if you have requested information from us or purchased the Services from us or if you provided us with your details in case registered for a promotion and, in each case, you have not opted out of receiving that marketing.

6.3.6 Third-party marketing
a. We will get your express opt-in consent before we share your Personal Data (not including your Health Data and Health Data Documents) with any company outside Topishi for marketing purposes.
b. You can ask us or third parties to stop sending you marketing messages at any time by logging into the Platform and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time at info@topishi.com.

6.3.7 Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Platform may become inaccessible or not function properly.

6.3.8 Change of purpose
a. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@topishi.com. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by Applicable Law.

7. Data Security


7.1 Your Personal Data shall be stored in accordance with the Applicable Law. We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

7.2 We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention and transfer


8.1 How long will we use your Personal Data? We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including the purposes of satisfying any accounting or reporting requirements or to Comply with a Legal or Regulatory Obligation. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. If you wish to exercise any of the rights set out above, please contact us at info@topishi.com.

8.2 Transfers of Personal Data outside of the United Arab Emirates The Personal Data that we collect from you may be transferred to, and stored at, a destination outside of the United Arab Emirates in accordance with the Applicable Law. By using the Platform and availing the Services, you agree that your Personal Data may be transferred to, and stored at, a destination outside of the United Arab Emirates. Except your Health Data and Health Data Documents, your Personal Data may also be processed by staff operating outside such jurisdictions who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of the Services and the provision of support services. Your Personal Data may be transferred, stored, processed and used by our affiliated companies and/or non-affiliated service providers in one or more countries outside your originating country.

9. No fee usually required


You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

10. What may we need from you?


We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


Effective as of December 15, 2021.